Manuel de Guia vs. COMELEC [G.R. No. 104712. May 06, 1992]

15 Aug



[C]ongress passed R.A. 7166, signed into law by the President on November 26, 1991. It is “An Act Providing for Synchronized National and Local Elections and for Electoral Reforms, Authorizing Appropriations Therefor, and for Other Purposes.” Respondent Commission on Elections (COMELEC) issued Resolution No. 2313, adopting rules and guidelines in the apportionment, by district, of the number of elective members of the Sangguniang Panlalawigan in provinces with only one (1) legislative district and the Sangguniang Bayan of municipalities in the Metro Manila Area for the preparation of the Project of District Apportionment by the Provincial Election Supervisors and Election Registrars, Resolution No. 2379, approving the Project of District Apportionment submitted pursuant to Resolution No. 2313, and Resolution UND. 92-010 holding that pars. (a), (b) and (c), and the first sentence of par. (d), all of Sec. 3, R.A. 7166, apply to the May 11, 1992 elections. Petitioner imputes grave abuse of discretion to COMELEC in promulgating the aforementioned resolutions, and maintained that election of Sanggunian members be “at large” instead of “by district”.


Whether or not the petitioner’s interpretation of Sec.3 of R.A. 7166 is correct in assailing the aforementioned COMELEC Resolutions.



NO. Petition was dismissed for lack of merit


Spirit and purpose of the law – The reason for the promulgation of R.A. 7166 is shown in the explanatory note of Senate Bill No. 1861, and that respondent COMELEC is cognizant of its legislative intent.

No law is ever enacted that is intended to be meaningless, much less inutile. We must therefore, as far as we can, divine its meaning, its significance, its reason for being. As it has oft been held, the key to open the door to what the legislature intended which is vaguely expressed in the language of a statute is its purpose or the reason which induced it to enact the statute.

The true import of Par. (d) is  that Sangguniang Panlungsod of the single-district cities and the Sangguniang Bayan of the municipalities outside Metro Manila, which remained single-districts not having been ordered apportioned under Sec. 3 of R.A. 7166  will have to continue to be elected at large in the May 11, 1992, elections, although starting 1995 they shall all be elected by district to effect the full implementation of the letter and spirit of R.A. 7166.

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Posted by on August 15, 2012 in Case Digests, Statutory Construction



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